UAE Ultimate Beneficial Owner (UBO) Regulations for Free Zone Companies 2026
UAE requires free zone companies to disclose their Ultimate Beneficial Owners. Here is the 2026 guide on UAE UBO rules and compliance.
In this guide:
What Are UAE UBO Regulations?
- UAE UBO regulations: Cabinet Decision No. 132 of 2023 (replacing 2020 rules); requires all UAE legal entities to maintain a register of Ultimate Beneficial Owners
- Purpose: Anti-money laundering (AML) and combating financing of terrorism (CFT) compliance
- Who must comply: All UAE companies including free zone companies
Who Is a UAE UBO?
- Natural person who ultimately owns or controls the UAE entity
- Threshold: Owns 25% or more shares or voting rights in the UAE company
- Control without ownership: A person who controls the company through other means (board rights, veto rights) is also a UBO
- If no 25%+ shareholder: The most senior manager (CEO/director) is deemed the UBO
UAE UBO Register Requirements
- Maintain internal UBO register: All UAE companies must maintain this; updated within 15 days of any change
- Information required: Full name, nationality, passport number, date of birth, UAE residential address, nature and extent of interest
- Submission to authority: Must also submit UBO information to the relevant authority (free zone authority or mainland DED)
UAE UBO Non-Compliance Penalties
- Late submission: AED 100,000 fine
- False information: Criminal liability possible
- Non-submission: Company can be delisted or licence suspended in extreme cases
Nominee Shareholders in UAE
- Using nominee shareholders to hide the real owner: Violates UAE UBO regulations
- Real UBO must be disclosed regardless of nominee structures